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Helping members navigate Covid-19

Covid-19 - member information

With the World Health Organisation characterising the Covid-19 outbreak as a pandemic (11 March), this page provides links to official information as well as some points that members may wish to consider in terms of operational matters. The key message
is that the majority of those who contract the virus will suffer little to no effect as a result, but precautionary measures to slow the spread of the virus may nevertheless cause difficulties for individuals and firms.

The health and safety of our people and members is paramount to the Association. We are keeping the situation under continuous review and adjusting plans accordingly to help protect our people in order for us to continue to provide you with the best service
that we can.

The weekly CSA Compliance Roundup email update (CSA Members only) also includes regular news regarding the Covid-19 outbreak. An archive of CSA Compliance Roundups can be accessed here (member sign-in required). If you are an employee of a CSA Member company and wish to receive these weekly updates please contact us.

Page contents (click to expand/collapse headers)

BEIS meeting and member survey (15/5/20) - The CSA hosted Zoom meeting with BEIS on Wednesday 13 May 2020 where members heard more about why the Association issued a survey to help Government understand the economic significance
and operational challenges that firms face and why it is crucial to have as much participation from members as possible. Listen to recording here.

CSA Compliance Roundups - Additional Covid-19 updates can be found within the weekly CSA Compliance Roundup. Click here to view (requires member sign-in).

The CSA continues to host a number of virtual meetings for members via Zoom. These are being very well attended and we thank members for taking the time to join us to help gather information in order for us to continue to lobby effectively.

We have been approached by a number of members concerning individual challenges they face as a consequence of the virus itself or, more frequently, adjustments they are making as a result of the response to Covid-19. In order to assist members
in responding to these challenges and to provide some insight into conversations, we have produced key considerations resources.

The FCA has created a webpage which outlines the publications or pieces of work that have been delayed as a result of the Covid-19 pandemic. This includes the interim report on the Credit Information Market Study, the FCA’s vulnerability guidance
and its directory of certified persons, which it states are due Q2 2020.

The FCA has published its feedback statement following the brief consultation on guidance setting out temporary relief for financial services customers. The FCA has also published its now finalised guidance alongside the feedback statement. The guidance
came into force on 14 April 2020.

The feedback statement provides additional context to the FCA’s decisions and guidance, as well as highlighting some areas of concern raised by regulated firms and their trade bodies.

The feedback
statement is available here and finalised guidance can be found here.

On 4 March the FCA published the following statement on Covid-19. Firms that are FCA regulated should note, in particular, that the FCA expects the same standards to be met and that firms should ensure that their systems and controls
are adequate and fit for purpose. It is clearly expected that firms will continue to meet regulatory standards and requirements to the extent reasonably possible.

We remain in close contact with other trade associations, the debt advice sector and HMT and will continue to engage with them over the coming weeks to share relevant information across our networks. We will share developments on this in due
course.

Members are also reminded that they have access to Croner’s free business helpline.

Croner have confirmed that they will remain available 24/7 to provide you with expert HR and
health & safety support.

The Croner website website has been updated with various Covid-19 resources:

As above, it is currently expected that in the majority of cases the virus will have a relatively minor effect in health terms. However, disruption to the movement of people and goods could present challenges to both individuals and businesses.
That could affect not only the way in which members conducts their business, but also that of their clients and the ability of customers to engage with members.

In light of those potential effects, it has been suggested that firms should review
their Business Continuity/Disaster Management plans, consider three broad aspects: how they and their employees might be affected; how their clients or their clients expectations might be affected; and how customers (such as those that they are seeking
to recover debts) from might be affected. Potential considerations will vary from member to member, but we have set out some examples of further questions that members may wish to ask themselves in the context of their Business Continuity Plans and
their ability to operate:

How will you function if staff are required to self-isolate or business premises become inaccessible (for example, is additional IT kit required)?

Is there sufficient flexibility in the IT infrastructure that staff could work remotely or from alternate sites?

How will you ensure data is adequately protected in the event of large scale home/remote working?

Will you still be able to process payments and is there a mechanism in place to ensure that customers are not affected in the event that you cannot adequately deal with payments or accounts?

Will adjustments be needed to communication strategies if staffing levels drop temporarily (for example, handling inbound calls following a large scale mailing)?

Will you have sufficient compliance resource available so that staff can perform their jobs effectively and with adequate oversight?

Have you contacted your clients to ensure that you understand what their expectations are (for example, if you have a service level agreement requiring outbound communication within the first 24 hours, what happens if staff availability is affected)?

How might customers, including those that do not contract the virus, be affected and how might that affect your ability to collect in the short to medium term?

Have you taken the potential effects of COVID-19 on customers into account in terms of your forbearance strategy?

The CSA office is now closed, with the full team working from home. All non-essential travel including training and networking events have been suspended and postponed respectively. We anticipate that we will be able to fully support the majority
of member queries as normal with staff being contactable via phone and/or email, through our ongoing virtual meetings, and all updates will be posted daily on our website.

We will be delivering apprenticeship workshops remotely via the Zoom digital learning platform.

We anticipate workshops will be delivered remotely until the end of July 2020, at which time we shall review the situation and provide an
update to apprentices and their employers.

Any questions relating to Zoom should be directed to the relevant CSA tutor or Zoe Dellow who will be able to offer you full support, alongside Colin Matthews,
our technical lead on Zoom at CSA Head Office.
Coronavirus (Covid-19): guidance for apprentices, employers, training providers, end-point assessment organisations and external quality assurance providers - view guidance.
Covid-19: Department of Education recommendations In order to support the sector during any disruption which may be experienced due to Covid-19 these are the initial recommendations from the Department for Education:

Apprentices who are ready for assessment – i.e. who reach gateway and cannot be assessed due to assessor illness or Covid-19 related measures, will be allowed to have a break in learning. This should protect funding and completion of apprenticeships
and should be reflected in the July completion rules. The normal breaks in learning process should be followed and therefore we only need notifying once a break in learning has exceeded four weeks. A break in learning must occur before the
learner is recorded as completed. Apprentices can go on a break in learning between completing the learning activity (learning actual end date) and the assessment, but there would be no requirement to record in this in the ILR as it will not
have an effect on funding.

Apprentices who experience gaps in training due to Covid-19 related illness in the workplace or off the job can classify this period as a break in learning. The normal breaks in learning process should be followed and therefore we only need notifying
once a break in learning has exceeded four weeks.

Usually breaks in learning are only permitted where they are learner driven, however we are aware that there may be occasion where an employer who is following government advice may take action that results in an apprenticeship have to be paused.
In these occasions a break in learning can be used where there will be a break of longer than four weeks. The normal breaks in learning process should be followed.

In order to maintain the integrity of high quality assessment of apprenticeships we are going to monitor the situation and will issue further advice and modifications relating to specific assessment methods if necessary.

We advise adhering to the current escalation process of raising EPA (end-point assessment) issues through EQAPs (external quality assurance providers) in the first instance.

There is a need for everyone (employer, provider, EPAO, Apprentice) to take a reasonable and balanced approach in these situations and to recognise that the health and wellbeing of individuals is a higher priority than performance measures.

We know that good communications between each of these parties is important to the successful delivery of EPA anyway. So, in these circumstances that communication becomes even more important.

The Institute for Apprenticeships and Technical Education (IfATE) will shortly be publishing guidance for this area in response to potential disruption from Covid-19.

In light of the current Covid-19 situation, the CSA has made the following decisions regarding CAI accreditation:

During this period we understand that maintaining company accreditation may be a challenge. We will maintain all companies accreditation status through to the end of May. We will continue to keep this under review.

If you have colleagues working at home, this may be an opportunity for them to catch up on some learning and prepare for their tests.

We have decided to temporarily allow tests to be taken at home for members of staff who are working from home or on furlough.

In addition to this, we would like to inform you that our Learning and Development team are all now working from home. We will continue to provide you with all the services and support we are able to during this time.

For those employers considering placing members of staff on furlough HMRC have issued additional guidance on furlough leave including how it impacts on any apprenticeships and any other forms of training they are able to undertake.

Furloughed employees and training

A furloughed employee can take part in volunteer work or training, as long as it does not provide services to or generate revenue for, or on behalf of your organisation.

A furloughed employee does not have to be paid the National Minimum Wage (NMW) if 80% of their wage falls below the NMW. However, if an employee is required to complete any training during furlough leave, this should be paid NMW.

HMCTS has a rolling guidance page relating to the Covid-19 outbreak. This page provides advice and guidance for all court and tribunal
users during the coronavirus outbreak and will be updated when new advice is available.

If any of your colleagues wish to receive email updates from the CSA please email us. If you have any colleagues who may have recently unsubscribed from our general membership updates, please encourage
them to re-subscribe as this will be a main point of contact with members with important information over the coming weeks and months ahead.

The Money & Pensions Service (MaPS) has convened an external task force made up of StepChange, Citizens Advice, Money Advice Trust, UK Finance and the FCA, to build a coordinated approach to public financial guidance in response
to the Covid-19 outbreak.

Working in a crisis webinar series - To support companies and staff the Money Advice Trust’s Vulnerability Lead Consultant Chris Fitch and subject matter experts have
developed a series of free webinars to help with challenges staff and customers are likely to face during this crisis. These practical webinars are designed for creditor staff working in front-line/customer-facing, management and specialist
roles and will provide advice and tools on how on how to deal with a range of situations, including customer bereavement and emotional and financial crisis.

Various authorities have stressed the importance of accessing sources of reliable and balanced information, and of adopting a cautious but measured response. Where possible, authorities are attempting to tackle misleading information. We have
listed below some links to official sources of guidance on the virus.

Government response page – contains information on the virus and links to the NHS and Public Health England website including a small amount
of guidance for employers and businesses.

Government has also published a summary of the measures to support those affected by the
virus including individuals, businesses and public services that were included in the Budget (11 March 2020). It should be noted that some of these changes may take a little time to work into the system and in most cases will not wholly replace
income. Members should be alert to the potential for slight differences of approach within devolved administrations.

The Coronavirus Large Business Interruption Loan Scheme will provide a government guarantee of 80% to enable banks to make loans of up to £25m
to firms with an annual turnover of between £45m and £500m. This will give banks the confidence to lend to many more businesses which are impacted by coronavirus. Facilities backed by a guarantee under CLBILS will be offered at commercial
rates of interest.

The Government has confirmed further support measures, including Bounce Back Loans and changes to Lifetime ISA rules - full launch details here.

BEIS has agreed measures with the energy industry to support vulnerable customers during the current crisis. The measures include ensuring prepayment and pay-as-you-go customers are supplied energy and encouraging firms to consider
re-assessing, reducing or pausing debt and bill payments. Firms should also consider referring individuals for third party debt advice depending on their circumstances. The government’s press release can be found here.

The European Data Protection Board (EDPB) has published a formal statement on the processing of personal data in the context of the Covid-19 pandemic. Of particular note are their comments on the processing of special category
personal data in the employment context and the potential need to rely on a basis of substantial public interest in the area of public health. They suggest that there may be national derogations enabling this – Schedule 1 Part 1 (3) of the
Data Protection Act 2018 sets out this potential legal basis.

The EDPB statement includes a brief FAQ section on employment and personal data.

The EDPB statement can be found here.
Schedule 1 of the Data Protection Act 2018 can be found here.

AiB has published their approach to consumers. Their on-going updates detailing their response to Covid-19 can be found here.
This page will be updated with further developments.

The European Central Bank (ECB) has announced measures to ensure supervised banks can respond appropriately to the Covid-19 outbreak.

Deferral of VAT payments as a result of Covid-19 The Chancellor announced a VAT payments deferral on 20 March to support businesses with cashflow during the Covid-19 pandemic.

This means that all businesses with a
UK VAT registration have the option to defer VAT payments due between 20 March and 30 June. Businesses have until 31 March 2021 to pay any VAT deferred as a result of this announcement.

Businesses do not need to inform HMRC if they
wish to defer payment. They can opt in to the deferral simply by not making VAT payments due in this period.

Businesses who normally pay by direct debit should cancel their direct debit with their bank if they are unable to pay. This
can be done online if they’re registered for online banking. They should do so in sufficient time so that HMRC does not attempt to automatically collect on receipt of their VAT return.

Should they wish, businesses can continue to make
payments as normal during the deferral period. HMRC will also continue to pay repayment claims as normal. Businesses must continue to submit VAT returns as normal.

For more information please go to GOV.UK and search “Deferral of VAT
payment”.

Additional information on changes to insolvency laws:
Under the plans, the UK’s Insolvency Framework will add new restructuring tools including:

- a moratorium for companies giving them breathing space for from creditors enforcing their debts for a period of time whilst they seek a rescue
or restructure;

- protection of their supplies to enable them to continue trading during the moratorium; and;

- a new restructuring plan, binding creditors to that plan

The proposals will include key safeguards
for creditors and suppliers to ensure they are paid while a solution is sought.

The government will also temporarily suspend the wrongful trading provisions to give company directors greater confidence to use their best endeavours
to continue to trade during this pandemic emergency, without the threat of personal liability should the company ultimately fall into insolvency.

Existing laws for fraudulent trading and the threat of director disqualification will
continue to act as an effective deterrent against director misconduct.

- Maintain the current supply of debt advice, including enabling more debt advisers to work remotely

- Anticipate supply and demand beyond the immediate-term and consider capacity requirements over next 12 months and beyond

- Plan for large scale recruitment and training of new advisers, to meet increased demand due to the economic downturn post Covid-19

Face-to-face support To protect the health and wellbeing of debt advice advisers and to avoid the spread of the virus there has been a significant reduction in the availability of face-to-face debt advice in the sector.

Creditors should be aware of temporary issues with their signposting processes. MaPS are actively working with face-to-face debt advice agencies to help maintain services via telephone and digital channels.